JBCE’s Answer to the Call for Evidence on Guidelines on the Implementation of the EU Rules on Forced Labour

06/03/2026

The Japan Business Council in Europe (JBCE) supports the European Union’s objective to eliminate products made with forced labour from the EU market and has contributed throughout the decision-making process leading to the adoption of the Forced Labour Regulation(FLR). Entering the implementation phase, JBCE welcomes the opportunity to share the perspectives of its members regarding the upcoming Guidelines.

On a general note, JBCE’s position focuses on predictable, risk based, and coherent implementation that:

1. provides clear guidance for economic operators, competent authorities, and other stakeholders that are consistent with existing international standards (i.e. ILO indicators, the UNGPs and OECD).
2. takes into account the resources required for preparatory work and investigations, which depend on the size of the economic operator and its level of involvement in the risk of forced labour; provides training and capacity building support
3. ensures transparent standards of evidence, access to the risk database and the EU's single portal, and consistent implementation across member states
4. prioritizes remedial measures over indiscriminate disengagement
5. ensures consistency with existing Industry standards, EU legislative requirements and evidence for proving sufficient due diligence implementation of human rights, including forced labour. (i.e. EUDR’s Due diligence statement, CSDDD, CSRD disclosures etc.)
6. fosters EU–Japan cooperation on capacity building and data sharing to address upstream risks.

 

Download documents: JBCE’s Answer to the Call for Evidence